FSRH consultation response: Statutory footing for ICSs is an important means to improve access to women’s health services

Posted 13 January 2021

Date: 13 Jan 2021

Type: FSRH Consultation Responses

We respond to NHS England / Improvement’s consultation on proposed legislative options to further develop Integrated Care Systems (ICS).

In our response, we make the following points:

  • Statutory footing for ICSs is an important means for ICSs to improve access to women’s health services, embedding them in the heart of the community.
  • We are clear that whatever form ICSs take, they must embed partnership working. A new statutory duty to collaborate should be introduced on all partners within systems. 
  • We support NHSE’s proposal to develop a single system-wide approach to strategic commissioning, with a focus on improving population health outcomes. 
  • NHSE’s offer for Local Authorities of closer collaboration for improved outcomes is well-intentioned. However, we strongly believe that solely relying on voluntary initiatives for collaborative commissioning will not suffice. History tells us that voluntary arrangements for commissioning governance and accountability between the NHS and Local Authorities have not worked well in the past. Co-commissioning can improve the quality and availability of women’s health services, increase access and reduce inequalities, but only with clear lines of accountability.
  • We believe the fragmentation of commissioning responsibilities will likely remain until there is only one, single accountable commissioner for women’s health at ICS level, and a clinical director, or similar, at national level holding accountability for commissioning and outcomes in women’s health. A single accountable commissioner would ensure that services are more joined up for women, meeting their healthcare needs across the lifecourse. It would also ensure a multidisciplinary workforce is better supported and resourced.
  • We believe it is crucial for every ICS to ensure that a medical Consultant in Sexual and Reproductive Healthcare is represented in ICSs governance bodies to ensure adequate leadership in women’s reproductive health commissioning and accountability through systems.
  • The proposals do not provide meaningful detail on workforce, the true bedrock of the health and care system. This is a serious omission, which we believe should be addressed through engagement with Colleges and Faculties.

Download our full response here

Read more about the consultation here